Privacy Policy
Prestige Leisure UK Limited
Privacy Policy
Prestige Leisure UK Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
1. Who we are
1.1. Prestige Leisure UK Limited (we/us) is a company registered in England under company registration number 02698261 and having its registered office address at Suite G1, Hartsbourne House, Delta Gain, Carpenders Park, Watford, England, WD19 5EF. We can be contacted by email at info@prestigeleisure.com.
1.2. We do not have a Data Protection Officer.
2. Definitions
Controller means a person or a legal person which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.
Data Subject a person who is identified by or identifiable from Personal Data.
GDPR the General Data Protection Regulation (2016/679), which is available here.
Personal Data means any information relating to an identified or identifiable natural person.
Processor means a person or a legal person which processes Personal Data on behalf of the Controller.
Special Categories of Personal Data Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.
Website www.prestigeleisure.com
3. About this document
3.1. This privacy notice takes effect from October 2023.
3.2. It is directed to all individuals whose Personal Data we process other than our officers, employees, workers and volunteers (but it does apply to candidates for any of these roles).
3.3. This notice sets out information about how we collect Personal Data, the categories of Personal Data we collect, the purpose for which we process Personal Data, the legal basis for processing, our legitimate interests in processing, how we share Personal Data and the rights of Data Subjects whose Personal Data we process. It applies to Personal Data collected by whatever means including without limit through our website.
3.4. On occasion, we may also provide more detailed processing information to a Data Subject in a separate privacy notice. Where we do so, that information will prevail over the information in this document in case of conflict.
4. Changes to the privacy policy and your duty to inform us of changes
4.1. We keep our privacy policy under regular review. This privacy notice may be updated from time to time.
4.2. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
5. Controller
5.1. We are the Controller in relation to all Personal Data which we collect.
6. The data we collect about you
6.1. We process Personal Data in relation to the following categories of Data Subject:
6.1.1. Our customers and representatives of our customers;
6.1.2. Delivery contacts;
6.1.3. Our shareholders and persons exercising significant control over our company;
6.1.4. Business contacts;
6.1.5. Candidates for employment with us (Candidates);
6.1.6. Suppliers and representatives of our suppliers;
6.1.7. Visitors to our website; and
6.1.8. Visitors to our premises.
6.2. We process the following types of information which are or may be Personal Data:
|
Candidate Data |
Work history, experience, qualifications, job title, information about disabilities and health conditions if this is disclosed by Candidates. |
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Commercial Records Data |
Personal Data comprised of records of sales and purchases of goods and services. |
|
Contact Data |
Names, addresses, email addresses, telephone numbers, facsimile numbers, job title, organisation, excluding Delivery Contact Data. |
|
Credit Reference Data |
Credit history and rating, trade references. |
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Delivery Contact Data |
Names, job title, organisation and delivery address, telephone number. |
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Employer Reference Data |
Employer references. |
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Financial Data |
Payment card information, bank account and sort code numbers, records of our financial transactions with you. |
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Incident Data |
Personal Data (including Contact Data) relating to injuries occurring at our premises involving visitors. |
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Marketing Data |
Records of marketing preferences and requests not to process Personal Data for marketing purposes. |
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Shareholder Data |
Entries in our register of members and register of people with significant control over our company, Contact Data relating to our shareholders. |
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Surveillance Data |
CCTV footage. |
6.3. We process the following Special Categories of Personal Data:
6.3.1. Incident Data; and
6.3.2. Special Categories of Personal Data included in Candidate Data.
6.4. We do not expect to process Personal Data relating to criminal convictions.
6.5. Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
6.6. It is a requirement before entering into any contract with us to provide us with your name, billing address, telephone number and a delivery address for the goods you are purchasing.
6.7. If you require credit to be made available, it is a requirement that you fully complete our credit reference form and arrange for trade references to be provided.
7. How we collect Personal Data
7.1. We use different methods to collect data from and about you including through:
7.1.1. Through the e-commerce facility in our website;
7.1.2. Through website contact forms and direct emails from people making enquiries with us;
7.1.3. When communicating with clients and suppliers (and their representatives) by telephone, in person or by email;
7.1.4. When making updates to our statutory register of members and register of people with significant control of our company;
7.1.5. When viewing or downloading information available from public sources (such as Companies House);
7.1.6. Through social media;
7.1.7. Through the use of CCTV;
7.1.8. During recruitment processes; and
7.1.9. By taking up external references (e.g. worker references or trade references) and undertaking external credit reference checks.
8. Purposes for which we will use your personal data
8.1. We will process Personal Data where processing is necessary for compliance with a legal obligation. This may apply to Contact Data, Commercial Records Data, Financial Data, Candidate Data and Shareholder Data.
We will process Contact Data, Delivery Contact Data, Commercial Records Data and Financial Data to perform our contracts with you and/or to take steps at your request prior to entering into a contract.
We may request your consent to certain forms of marketing communications and where we do so, consent is the basis upon which we will process your Personal Data for that purpose. We may ask you to consent to other forms of processing from time to time and where we do, consent will be the legal basis for that processing.
Unless we are processing Personal Data on the basis of consent, the table below sets out a description of the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
|
Purpose |
Categories of personal data affected |
Lawful basis for processing including basis of legitimate interest |
|
To sell our goods and services |
Contact Data, Delivery Contact Data, Commercial Records Data, Financial Data |
Selling our goods and performance of a contract with you. |
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To procure and receive supplies of goods and services |
Contact Data, Commercial Records Data |
Procuring and receiving supplies of goods and services and performance of a contract with you. |
|
To perform credit checks and make decisions about applications for credit |
Contact Data, Credit Reference Data, Commercial Records Data, Financial Data |
Performing credit checks and making decisions about applications for credit which are necessary for our legitimate interests. |
|
To comply with legal obligations |
Incident Data, Commercial Records Data, Contact Data, Financial Data, Shareholder Data |
Necessary to comply with our legal obligations. |
|
To investigate and enforce our legal rights |
All of the Personal Data we process (other than Special Categories of Personal Data) |
Investigating and enforcing our legal rights. |
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To defend legal claims which may be made against us or our officers, employees or workers |
All of the Personal Data we process |
Necessary for our legitimate interests for running our business. |
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To carry out administrative activities, including processing returns and refunds, keeping accounting ledgers and tax records, improving our systems and procedures |
Contact Data, Delivery Contact Data, Commercial Records Data, Financial Data |
Necessary for our legitimate interests for running our business and provision of administration. |
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To manage accounts and undertake direct marketing |
Contact Data, Marketing Data
|
Necessary for our legitimate interests to develop and grow our business and our offering and to inform our marketing strategy. |
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To complete reorganisations and sales of our assets and undertaking(s) |
All of the Personal Data we process |
Necessary to develop and grow our business. |
|
To assist customers and people making enquiries with us by introducing business to suppliers of products and services we do not offer |
Contact Data |
Necessary to inform our marketing strategy, to develop and grow our business and to maintain client and customer relationships. |
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To keep a record of your consent or request not to receive marketing communications |
Contact Data, Marketing Data |
Necessary for our legitimate interests to keep our records updated and to inform our marketing strategy. |
|
To process payments and refunds |
Contact Data, Financial Data |
Necessary for our legitimate interests to recover debts due to us and necessary for the performance of a contract with you. |
|
To assess a Candidate’s suitability for a position within our business, to manage the recruitment process |
Contact Data, Candidate Data, Employer Reference Data |
Necessary for recruitment and to develop and grow our business. |
|
To safeguard our assets and personnel |
Surveillance Data |
Necessary to ensure continuity and growth of our business. |
8.2. We will process Special Categories of Personal Data on the following lawful bases:
|
Lawful basis |
Personal Data affected |
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Processing is necessary to comply with obligations arising under social security law; processing is necessary for our legitimate interest of defending legal claims which may be made against us or our officers, employees or workers |
Incident Data |
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Processing is necessary to comply with obligations arising under employment law; processing is necessary for our legitimate interest of defending legal claims which may be made against us or our officers, employees or workers
|
Special Categories of Personal Data included within Candidate Data. |
9. Marketing
9.1. We may request your consent to certain forms of marketing communications and where we do so, consent is the basis upon which we will process your Personal Data for that purpose. We may ask you to consent to other forms of processing from time to time and where we do, consent will be the legal basis for that processing.
9.2. You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you.
9.3. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase.
10. Google Analytics
10.1. We use Google Analytics and website tools for collecting analytical information about the use of our website. We use settings which mean that online identifiers such as IP addresses are not collected and we do not combine analytical information with other Personal Data we hold to identify or profile you. Google uses information collected through Google Analytics in accordance with its privacy notice available at https://policies.google.com/privacy/partners?hl=en-GB&gl=uk.
10.2. We are not responsible for the processing of Personal Data by Google.
11. Data Retention
11.1. We will retain your Personal Data only for as long as is necessary to achieve the purposes (or any compatible purposes) for which it is processed. The retention period applying to Personal Data will depend upon the applicable legal and regulatory requirements, which may change over time, and also upon events occurring after the time of collection, such as the occurrence of a legal claim or the exercise of a data subject right (such as the right to request that we do not use your Personal Data for marketing purposes).
12. Automated decision making
12.1. Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We do not envisage that any decisions will be taken about you using solely automated means. We will notify you in writing if this position changes.
13. International transfers
13.1. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
13.1.1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
13.1.2. Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
13.2. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
14. Recipients of Personal Data
14.1. We transfer or may transfer Personal Data to the recipients set out in the table below.
|
Recipient or category of recipient |
Categories of Personal Data affected |
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Our employees, officers and workers |
All of the Personal Data we process |
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Our customers and people making enquiries with us |
Contact Data (relating to other suppliers and service providers) |
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Providers of services to us, including our IT service providers, self-employed consultants, couriers, credit reference agencies, insurers and professional advisers, including solicitors, advocates, insurance brokers, auditors and accountant |
All of the Personal Data we process |
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Courts and tribunals |
All of the Personal Data we process |
|
Suppliers of goods and services which we do not offer |
Contact Data |
|
Public bodies including keepers of public registers, the health and safety executive, the Information Commissioner’s Office, HMRC |
Contact Data, Commercial Records Data, Incident Data, Shareholder Data
|
|
Law Enforcement Agencies |
All of the Personal Data we process |
|
Successors in title to our business(es) |
All of the Personal Data we process |
15. Your rights
15.1. You have the right to:
15.1.1. Request access to your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
15.1.2. Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
15.1.3. Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
15.1.4. Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
15.1.5. Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
15.1.6. Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
15.1.7. Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
15.1.8. Complain to the supervisory authority in connection with our processing of your personal data. You can exercise this right by contacting the Information Commissioner’s Office at https://ico.org.uk/.
16. Security
16.1. We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know.
16.2. Our websites may contain links to other websites of interest. However, once you have used one of these links to leave our website, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Privacy Notice. You should exercise caution and look at the privacy notice applicable to the website in question.
17. Contact us
17.1. If you have any questions about our processing of Personal Data or would like to exercise one of your legal rights, please contact us at info@prestigeleisure.com.
17.2. Guidance on data protection law is available from the Information Commissioner’s Office at https://ico.org.uk/.
Download the PDF Version of our Privacy Policy here: Privacy Policy - 05 October 2023(11752948.5).pdf